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    <title>2012 (11) TMI 942 - ITAT CHENNAI</title>
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    <description>A composite share-transfer arrangement was treated as giving rise to capital gains only in proportion to the shares actually transferred in the relevant year. Because only 50% of the shares passed in assessment year 2007-08 and the balance of consideration and transfer depended on later conditions and completion of the transaction, the entire gain could not be brought to tax in that year. The deeming principle of transfer and part performance was held inapplicable on the facts, as complete conveyance and possession had not been obtained in the relevant sense. Accordingly, capital gains were taxable only to the extent attributable to the 50% shares transferred in assessment year 2007-08, with the balance taxable in the later year.</description>
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      <title>2012 (11) TMI 942 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=218927</link>
      <description>A composite share-transfer arrangement was treated as giving rise to capital gains only in proportion to the shares actually transferred in the relevant year. Because only 50% of the shares passed in assessment year 2007-08 and the balance of consideration and transfer depended on later conditions and completion of the transaction, the entire gain could not be brought to tax in that year. The deeming principle of transfer and part performance was held inapplicable on the facts, as complete conveyance and possession had not been obtained in the relevant sense. Accordingly, capital gains were taxable only to the extent attributable to the 50% shares transferred in assessment year 2007-08, with the balance taxable in the later year.</description>
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